companies have PE in India. It is the allegation of the
Assessing Officer that reinsurer had fixed place of PE or an
agency PE ... PE in India.
(d) The services rendered by the subsidiary of
NRRI does not constitute a Service PE or
Agency PE of the NRRI
patently wrong in holding UOPIPL as the dependent agency PE of the assessee in India. Reliance was placed on behalf of the assessee ... activity which could be construed of creating a dependent agency PE of the assessee in India, the AO was not justified in holding that
agent.
The Assessing Officer took the above said Indian company as agency PE of the
assessee. The AO also held that the business premises ... assessee.
(b) Whether Freight Connection (India) Pvt. Ltd. would constitute agency PE
of the assessee.
(c) Whether place of business of Freight Connection (India
PE of the assessee in India. The AO treated
SRSIPL not only as a service PE of the assessee but also as agency PE/ DAPE ... SRSIPL and its activities constitute PE of the assessee
or whether SRSIPL can be considered as a Service PE/ Agency PE of the assessee
place PE of the assessee. Insofar as MSC
Agency (India) Pvt. Ltd. constituting an agency PE is concerned, he submitted that MSC
Agency (India ... PE,
the PE must economically own the ships, in that the PE must have full control over
the ships, for example. the PE should
companies have PE in India. It is the allegation of the
Assessing Officer that reinsurer had fixed place of PE or an
agency PE ... PE in India.
(d) The services rendered by the subsidiary of
NRRI does not constitute a Service PE or
Agency PE of the NRRI
companies have PE in India. It is the allegation of the
Assessing Officer that reinsurer had fixed place of PE or an
agency PE ... PE in India.
(d) The services rendered by the subsidiary of
NRRI does not constitute a Service PE or
Agency PE of the NRRI
treated as a PE".
18. In regard to the agency PE it was submitted that subsequent to 2005
there is no role ... Sabre GLBL Inc.
17
DRP has not examined the Agency PE.
24. Findings; Now giving thoughtful consideration to the submissions
and the matter on record
treated as a PE".
18. In regard to the agency PE it was submitted that subsequent to 2005
there is no role ... Sabre GLBL Inc.
17
DRP has not examined the Agency PE.
24. Findings; Now giving thoughtful consideration to the submissions
and the matter on record
treated as a PE".
18. In regard to the agency PE it was submitted that subsequent to 2005
there is no role ... Sabre GLBL Inc.
17
DRP has not examined the Agency PE.
24. Findings; Now giving thoughtful consideration to the submissions
and the matter on record
